India and the United Kingdom offer different institutional logics and evolutionary paths in the field of transgender legal recognition. India has been led by judicial activism through the pronouncement of a landmark NALSA judgment that established self-identification as the constitutional standard, yet the Transgender Persons (Protection of Rights) Act, 2019 introduced a District Magistrate certification procedure, creating a structural tension between judicial idealism and legislative implementation. The UK, by contrast, built its framework on the Gender Recognition Act 2004, which channels legal recognition through the medicalised assessment of the Gender Recognition Panel; its anti-discrimination architecture is more mature, but self-identification reform has been repeatedly stalled in political contestation. By comparing the recognition models of these two countries, procedural obstacles and institutional tensions, this paper reveals a shared dilemma: the formal expansion of legal recognition does not necessarily produce substantive autonomy. India confronts an inversion of "judicial progress—legislative regression," while the UK is caught in the paradox of "robust protection—conservative recognition."